How is this different from our existing AI policy or MRM framework?
Your existing AI policy was probably built for production model risk (SR 11-7 / OCC 2026 model risk guidance / NIST AI RMF). That framework governs production AI/ML systems that make business decisions — credit models, fraud detection, AML monitoring. This kit governs the employee-facing layer above that: ChatGPT, Claude, Copilot, Gemini, and AI features embedded in third-party SaaS. Production AI/ML systems still go through your MRM program; this kit covers the part of AI use that sits in front of employees.
Will employees actually use the intake form, or will they just go around it?
The structural answer is the Pre-Approved Use Cases list (Tab 5). For the 15 common patterns on the list, employees do not need an intake — they self-serve. The intake is only for new tools, new use cases for approved tools, or new data classes within an approved use case. That keeps the friction low. The other structural answer is detection: DLP and browser allow-list backstop the policy, and the AI Incident Response runbook treats shadow AI as an intake event rather than a discipline event — the goal is to surface the underlying use case and add it to the Pre-Approved list, not punish individuals.
What's in the Worked Example?
Northstar Lending — a fictitious mid-size consumer lender (~600 employees). The example walks through: program setup (Data Classification Matrix, Approved Tool List customization, Pre-Approved Use Cases tailored, Vendor DD Register populated), an auto-approved intake request (marketing analyst summarizing public earnings calls), an escalated intake request (customer support using customer data in Claude for Enterprise — Conditional Approval with specific conditions), two incidents (a shadow AI browser extension discovered via DLP, and a Critical MNPI exposure when a finance team member pasted pre-earnings draft language into consumer ChatGPT), and the annual attestation results.
How does the Data Classification × Tool Tier Matrix work?
Four data classes (Public, Internal, Confidential, Restricted) mapped against three tool tiers (Consumer / Enterprise / Prohibited). Public can go in any tier. Internal and Confidential are Enterprise-only (with no-training opt-out and DPA in place). Restricted (MNPI, PHI, credentials, attorney-client privileged) is generally prohibited in any AI tool. The matrix is the load-bearing piece of the policy — what you input determines what tier of tool you can use.
What's on the Approved Tool List?
Starter entries for Microsoft 365 Copilot, Claude for Enterprise, GitHub Copilot Business, and ChatGPT Enterprise (Enterprise tier, approved for all non-Restricted data classes); ChatGPT free, Claude.ai consumer, Google Gemini consumer (Consumer tier, restricted to personal use with Public data only); and explicit Prohibited entries for open-source local LLMs (Ollama, LM Studio), unapproved AI browser extensions, and DeepSeek / sovereign-access AI services. You customize the list to your actual tenant.
Does this cover the Colorado AI Act and similar state laws?
The kit reflects emerging 2026 state AI law expectations including the Colorado AI Act (revised effective date June 30, 2026 — verify current status with counsel), which regulates high-risk AI systems making consequential decisions. The Prohibited Uses include AI-only adverse-action decisions about customers without meaningful human review — an approach informed by ECOA, FCRA, and the Colorado AI Act's direction toward meaningful human oversight of consequential automated decisions; the specific obligations of each regime should be confirmed with counsel for your products and jurisdictions. For EU AI Act exposure, additional review with EU counsel is recommended; the framework is structurally compatible but the kit does not include EU-specific compliance attestations.
How long does it take to roll out?
30–60 minutes for setup: align Data Classification Matrix to your existing Information Classification Policy, populate Approved Tool List with your tenants, customize Pre-Approved Use Cases, populate Vendor DD Register. Then 30 days for employee training and annual attestation, coordinated with HR. The Manager Talking Points appendix gives leaders the script for team rollout.